54
Pennsylvania Health Insurance Exchange Authority Pennsylvania Health Insurance Exchange Authority Board of Directors Meeting February 19, 2020

Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

  • Upload
    others

  • View
    0

  • Download
    0

Embed Size (px)

Citation preview

Page 1: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Pennsylvania Health Insurance Exchange Authority – Board of Directors MeetingFebruary 19, 2020

Page 2: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Meeting Agenda

1. Preliminary Matters

2. Standard Administrative Updates

3. Standard Technology and Operations Update

4. Branding Update

5. Update from Chini Krishnan of GetInsured

6. Review and Discussion of the 2021 Plan Certification Requirements and Process

7. Notice of Benefit and Payment Parameters

8. Presentation of the Employee Handbook

9. Adjourn

Exchange Authority | 2

Page 3: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Preliminary Matters

3

Page 4: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Administrative Updates

4

Page 5: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Updates

▪ Personnel

▪ Stakeholder Engagement

▪ Brokers

▪ Insurers

▪ Advocates

▪ Advisory Council

▪ State-Based Exchange partners

Administrative Updates

Exchange Authority | 5

Page 6: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

▪ Insurance Agents & Brokers roundtable meeting

▪ Introduced the Exchange Authority

▪ Discussed transition approach

▪ Policy process, including stakeholder feedback.

▪ Offered to create a broker question form to receive questions and feedback

▪ Briefed on plan certification proposed policy

▪ Broker certification policy – TBD

▪ Broker data migration from the Federally Facilitated Marketplace

▪ Limited data from FFM, need to work with PID and broker community to try to fill in gaps

▪ Complete broker data required to successfully migrate brokers

Stakeholder Engagement

Brokers

Exchange Authority | 6

Page 7: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

▪ EDI Technical Working Group (weekly)

▪ Setting up Connectivity

▪ Addressing technical questions after insurer review of EDI technical documentation

▪ Pay Now payment redirect schema discussed

▪ Insurer Policy Working Group (bi-weekly)

▪ Introduced a variety of policies, including plan certification proposals,

▪ 2 weeks for carriers to provide feedback via webform

▪ Late addition for feedback was no APTCc on zero dollar renewals

▪ Service Coordination Working Group

▪ TBD

▪ Information Sharing

▪ SharePoint site live

▪ Carriers updating contact list to get access to SharePoint

▪ Comprehensive question and answer log available

▪ Recordings of working group meetings will be available on SharePoint

Stakeholder Engagement

Insurers

Exchange Authority | 7

Page 8: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

▪ Advocates

▪ Exchange Assister After Action Review conducted (2/14)

▪ Scheduled an initial meeting with the PA Coalition for Oral Health (2/21)

▪ Worked with Advancing Strategies to Align Programs to develop a list of 20+ statewide community

groups. Will engage these partners via a Working Group for ongoing feedback

▪ Advisory Council

▪ First meeting 2/7, all but legislative appointees in attendance

▪ Established the mission of the Council -- to provide a forum for input and discussion of issues important

to improving the accessibility and affordability of individual market health coverage for Pennsylvanians.

▪ Assessing the feasibility of the Council’s recommendation to meet 3+ times during year one

▪ Meeting topics included: Exchange overview, governance, plan certification, pending tech/ops/policy

decisions, the Exchange Assister program

▪ Other State-Based Exchanges

▪ Meeting regularly with Nevada and New Jersey

▪ Actively sharing documents with New Jersey

Stakeholder Engagement

Advocates, Advisory Council, and Others

Exchange Authority | 8

Page 9: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Standard Technology and Operations Update

9

Page 10: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Agenda

▪ Stars on a String Status Report

▪ System Requirements and Design Process

Standard Technology and Operations Update

Exchange Authority | 10

Page 11: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June
Page 12: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

▪ Requirements Finalization Will Involve Integration of Information From Multiple Sources:

▪ Identified Items From PA Exchange Authority and UAT Team Review of System and Preliminary Sizing

▪ Items From GetInsured’s Product Development Roadmap for 2020

▪ Priority Items From the NJ Exchange Authorities Review of the System

Note: several categories of final requirements will still be open, including: screen text, notice language and

content, & system color schemes and branding.

▪ Integration and Draft Finalization Is Targeted for End of This Month

▪ Team Will Align Priorities Internally Prior to Reviewing with GetInsured

▪ Team Will Agree With GetInsured Which Items Are Regulatory and Must-Haves

▪ Team Will Work With GetInsured to Confirm Priority Delivery Items

▪ Team Will Subsequently Craft Delivery / Release Plan With GetInsured to Deliver Identified Priority

Items

▪ Lastly, Joint Team Will Determine Method of Preserving Remaining Requirements for Review in

Subsequent Year Prioritizations

System Requirements and Design Process

Exchange Authority | 12

Page 13: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Decision Policy Goal(s) Benefits Challenges

Default APTC

Percentage

(On Initial

Application)

Provide best customer

experience possible

• Setting value at less than

100% could lessen

chances that customers

have to pay more in

taxes at the end of the

year

• Presenting customers plans that cost

more (if less than 100% APTC is

applied) could discourage some

purchases

• Could be significant need for technology

work to implement not only default

changes, but shopping flow changes

Exchange Authority | 13

Informational Decisions

▪ Summary of Stakeholder Feedback:

▪ Broad stakeholder support for the need to focus on educating customers about the need to estimate

their income as accurately as possible, timely report any changes to income, and talk to their tax

advisor to understand potential tax implications.

▪ Potential tax consequences outweighed the risk that initially showing plans with less than the

maximum available APTC might result in customers not enrolling or enrolling in a plan with more

cost sharing or lower AV than they wanted.

▪ Staff Decision:

▪ Default to 100% of maximum APTC

▪ Focus on communications to remind customers of potential tax consequences of taking more APTC

than eligible, need to report changes to projected income, etc.

Page 14: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Decision Policy Goal(s) Benefits Challenges

Default APTC

Percentage

(At Auto-Renewal)?

Provide best customer

experience possible

• Setting value at less than

100% could lessen

chances that customers

have to pay more in

taxes at the end of the

year

• Presenting customers plans that cost

more (if less than 100% APTC is

applied) could discourage some

purchases

• Could be significant need for technology

work to implement not only default

changes, but shopping flow changes

Exchange Authority | 14

Informational Decisions

▪ Summary of Stakeholder Feedback:

▪ Stakeholder feedback was mixed. Stakeholders generally supported trying to apply the same APTC

to autorenewal policies whenever possible, while also recognizing that premiums and 2nd lowest cost

silver plan change year over year so it’s not a perfect comparison.

▪ Staff Decision:

▪ Pursue feasibility of applying prior year’s APTC percentage to autorenewal policy (would require IT

changes).

▪ Focus on communications to remind customers of potential tax consequences of taking more APTC

than eligible, need to report changes to projected income, and review their autorenewal policy each

year at OEP.

Page 15: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Decision Policy Goal(s) Benefits Challenges

Two-Factor

Authentication for

Brokers & Assisters

(e.g. Navigators,

CACs)?

Secure customer

information without

causing undue

operational burden on

community partners

• Provides extra layer of

security for customer

information for those

customers working with

brokers and assisters

• May make operational process slightly

more challenging for these partner users

Exchange Authority | 15

Informational Decisions

▪ Summary of Stakeholder Feedback:

▪ Brokers and assisters supported this requirement, with no operational concerns. Some confirmed

that this is their current process.

▪ Broad support from stakeholders to require additional levels of security for users with access to other

customer’s data.

▪ Staff Decision:

▪ Require two-factor authentication for brokers & assisters

Page 16: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Branding Update

16

Page 17: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 17

Page 18: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 18

Page 19: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 19

Page 20: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

SHADAC analysis of the United States Census Bureau's American Community Survey (ACS).

Exchange Authority | 20

Page 21: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 21

Page 22: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 22

Page 23: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 23

Page 24: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 24

Page 25: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 25

Page 26: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Exchange Authority | 26

Page 27: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Update from Chini Krishnan of GetInsured

27

Page 28: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

© Copyright GetInsured 2020 28

January 16-17

Call Center Kickoff

February 19, 2020

Board Meeting

PENNSYLVANIA

Page 29: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

© Copyright GetInsured 2020 29

Agenda

Topic

About GetInsured

Key Focus Areas for the Commonwealth

Call Center Update

Closing Q&A

Page 30: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

© Copyright GetInsured 2020 30

Founded in 2005

Deep roots for more than 12 years in Atlanta,

Georgia and Mountain View, California

Public Sector Cloud Transitions

We are the leading technology provider for

states transitioning off of healthcare.gov to

state-based marketplace solutions

500+ Employees

World-class engineering and healthcare talent

from Amazon, eBay, Google, Yahoo!

Market Leader

● Venture Backed -- Bessemer

● Dominant Market share

● Rapidly growing recurring revenue

● Consistently Profitable

● World-class Team

Introduction to GetInsured

Our mission is to deliver the best cloud-based solutions to states (and their partners -- carriers, brokers and consumers)

Enrollees serviced each year,

80% of all SBM enrollments

State-Based Marketplaces

leverage GetInsured technology

and/or customer service centers

8,000+agents using the

GetInsured platform

1,000health plans on the

GetInsured platform

2M 7

Footprint

Shankar Srinivasan

GM & Co-Founder

Shankar leads the company’s product

management function.

Chini Krishnan

CEO & Co-Founder

More than 20 years of experience in the

high technology industry

Page 31: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

© Copyright GetInsured 2020 31

The Pennsylvania Project Leads

Dawn Hughan

DDI Manager

Richard Draper

Call Center Lead

Michael Daugherty

Call Center Director

Danielle Hubbard

Trainer/Facilitator

Pla

tfo

rm/P

rog

ram

Ma

na

ge

me

nt

Co

ns

um

er

As

sis

tan

ce

Cen

ter

John Arthur

Change Mgmt

Call Center Lead

Yannick Deville

Telephony Engineer

Ashley Hargrett

Senior Operations

Rajiv Chawla

Project Manager

Chini Krishnan

CEO

Shankar

Srinivasan

COO

Paul Neutz

SVP, Business

Development

Sephy Hambaz

Chief of Staff &

VP Operations

Marc

Cooperson

Director, PM of

Platform

Page 32: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

© Copyright GetInsured 2020 32

1,000+ Plans

Our Customers

2005 - 2010 2010 2015 - present

We built the ‘Travelocity’

for health insurance prior

to the ACA. We made the platform easy to

use for brokers and agents. Our technical platform functions as an

“Exchange-in-a-Box” for states.

8,000 Brokers

Consumer MarketplaceBrokers & Agents State-Based

Marketplaces

2.5M+ Enrollments

Page 33: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

© Copyright GetInsured 2020 33

JAN

PHIEA Roll Out - Key Focus Areas

DECNOVOCT

Connection to Federal Hub 9/1

CMS Approval and Authority to Connect 9/1

SEP

FFM Migration

FFM Catch Up

Data 12/17

AUGJULJUNMAYAPRMARFEB2020 JAN

Contact

Center

Lease

agreement

signed

Contact Center

Detailed project plan Contact Center

Facility move in

Contact Center

First class for CSRs

6/1 - 10/15

Contact Center

Infrastructure

Stand up

OEP

Begins

Contact Center

Operational 10/9

Broker

Training

9/17 - 10/26

2021 Plans

Loading

Data Migration

Starting 9/9

Platform Release 2

9/21

Insurer Testing

Complete 9/26

Platform Release 1 6/22

Auto-Renewals

10/12 - 10-16

Insurer Integration

Starts 2/14

Platform Requirements

Complete 3/6

Medicaid Integration

Complete 6/30

2021

Coverage

Begins

Platform

Release 3

1/4

Security

Platform

Insurers

Contact Center

Security Documentation

initiated

Page 34: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

© Copyright GetInsured 2020 34

New Call Center Space Update

Cumberland Center

3065 Akers Mill Rd SE, Atlanta, GA 30339

● New lease signed on former Sprint Call

Center space

● Agreement signed with Nelson Architectural

Engineers

● RFPs out to General Contractors (GC) due

back Feb 21

● GC selection set on or before Feb 28

● Next phase SDs (Schematic Design) and DDs

(Design Development)

● June to July move-in date

● Sits on the most reliable power grid in Atlanta

● Existing backup high capacity generator

capable of powering entire building

Page 35: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

2021 Plan Certification Requirements and Process

35

Page 36: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Purpose

▪ Plan certification policy provides guidance to insurers regarding successful participation in

Pennsylvania’s exchange for 2021.

▪ Exchange as “active purchaser” - determine plans to be in the best interest of qualified individuals (45

CFR §155.1000(c)(2)).

▪ Plan certification requirements are in addition to compliance with federal and state rules.

Goals

▪ Access to high quality, comprehensive, affordable health coverage for Commonwealth residents

▪ Access to tools and resources to help customers make the best decision for their unique needs

Process

2021 Plan Certification

Exchange Authority | 36

Engage Stakeholders

Stakeholder Feedback & Staff Recommendations

Board Decision

Page 37: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Proposal Policy Goal(s) Benefits Challenges

Neither the Insurer nor any

subsidiary or affiliate of the

Insurer may offer short-term

limited duration (STLD) plans

in the individual market

within the Commonwealth for

the 2021 plan year.

Provide high quality,

affordable,

comprehensive health

coverage to

Commonwealth residents

• Ensure Commonwealth

residents have access to quality

comprehensive health coverage

• Prevent splitting individual

market risk pool, thereby

increasing costs of exchange

plans

• Would limit flexibility of

insurers offering

exchange coverage

from starting to offer

STLD plans (no

exchange insurers

currently offer STLD)

Exchange Authority | 37

▪ Summary of Stakeholder Feedback:

▪ Broad support across consumer groups, brokers, assisters, insurers, providers/health systems. Concerns included:

▪ STLD plans are confusing to customers, misleading them to think they have comprehensive coverage when they don’t

▪ Healthy individuals will be lured out of the individual market risk pool due to lower premiums of STLD plans, thereby

increasing costs for marketplace plans.

▪ 5 Insurers supported, 2 Insurers expressed concern about “wanting to maintain flexibility to offer this type of product

in the future depending upon market demands” and “unnecessarily segments the health insurance market by forcing

carriers to choose between participating on the SBE or participating in the STLDI market”

▪ 1 Insurer questioned whether this this restriction “falls outside of PHIEA scope of regulatory authority”

▪ 1 Insurer thought that the subsidiary/affiliate language was too broad and therefore overly restrictive.

▪ Staff Recommendation: Adopt requirement #1 as written

▪ STLD plans are confusing to consumers, are not comprehensive coverage, and adversely impact the individual

market risk pool which would increase costs to exchange coverage

2021 Plan Certification

Proposed Requirement #1

Page 38: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Proposal Policy Goal(s) Benefits Challenges

Opioid crisis

guidelines,

implemented by

Medicaid in March 2018

Commonwealth priorities

to address opioid crisis

• Ensures all plans have

comprehensive access to

coverage addressing opioid crisis

• New insurers to exchange would

be offering same coverage

current exchange insurers offer

• Risk of being considered a

new mandate with

unintended cost impact

Exchange Authority | 38

▪ Summary of Stakeholder Feedback:

▪ General support across consumer groups, brokers, assisters, insurers, providers/health systems. Support included:

▪ Importance of access to Medication Assisted Treatment (MAT) in addressing opioid crisis

▪ Protection that new entrants to marketplace will include coverage already provided by current insurers

▪ 1 Insurer requested clarification regarding specific drug formulary

▪ 1 Insurer expressed concerns about whether this could be interpreted to be a new mandate and therefore cost would

be responsibility of state, and questioned whether this restriction “falls outside of PHIEA scope of regulatory authority”

▪ Staff Recommendation: Withdraw Requirement #2 from 2021 Policy

▪ Risk of cost impact if this were to constitute a new mandate. Current draft federal rule may provide clarity or change

interpretation of this provision.

▪ Current exchange insurers already include this coverage so requirement not needed to ensure access at this time.

2021 Plan Certification

Proposed Requirement #2

Page 39: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Proposal Policy Goal(s) Benefits Challenges

Consistent Rate of

Producer/Broker

Commissions

Provide Commonwealth

residents with access to

licensed producer

services, including plan

recommendations

• Allows producers to plan

for participation in

exchange, including

staffing, sales strategy,

etc.

• Not current practice for most current

exchange insurers

Exchange Authority | 39

▪ Summary of Stakeholder Feedback:

▪ Support from some stakeholders (consumer groups, assisters, brokers).

▪ Brokers report that the lack of consistent commission schedules over the past years (including commissions being

reduced suddenly mid-year) has made it difficult for them to make time/resource investment to participate in exchange,

and sudden reduction/elimination of commissions has caused them significant disruption

▪ 2 Insurers reported that this was their current practice.

▪ Insurers (5 of 7) reported opposition as this would be a change to their current practice. Concerns included:

▪ inflexible, would "encroach into business decisions,” would lead to insurers removing commissions altogether,

▪ it doesn’t take into account the higher effort required for a new sale versus a renewal, and

▪ 1 Insurer noted that they would like to be able to pay lower commissions for SEP enrollments due to “higher overall

volatility, partial-year premiums, and some increased risk of fraud”

▪ Staff Recommendation: Withdraw Requirement #3 for 2021

▪ Customer access to a robust network of brokers is an important tool to support customer decision making.

▪ While we recognize that we don’t know what we don’t know, we see the value that consistent commission schedules brings to

ensuring broker participation. We plan to monitor in 2021 and reconsider for 2022 as appropriate.

2021 Plan Certification

Proposed Requirement #3

Page 40: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Proposal Policy Goal(s) Benefits Challenges

Advanced Notice of

Producer/Broker

Commission

Payment Schedule

Provide Commonwealth

residents with access to

licensed producer

services, including plan

recommendations

• Ensures brokers have sufficient

advance notice to make the time,

resource, and training investments

to participate in exchange for

upcoming year

• Current industry practice

provides minimal advanced

notice

• Would require insurers to

finalize decisions earlier

Exchange Authority | 40

▪ Summary of Stakeholder Feedback:

▪ General support from stakeholders (assisters, brokers, consumer groups).

▪ Brokers reported that currently they receive minimal to no advanced notice (as little as 5 days) which makes it difficult for

them to plan for and prepare for participation on exchange. Simply knowing commission schedules further in advance

would be helpful.

▪ 5 of 7 Insurers supported, with some requesting modifications to the proposed 90 day timeframe and exceptions for late

plan filing changes with PID

▪ Opposition from 2 Insurers who expressed concerns including “can potentially hurt competition between insurers and between

brokers”, “potential to equalize and stabilize commissions above what would otherwise be competitive levels with resulting price

increases”, and concern about ability to change commissions later in the year.

▪ Staff Recommendation: Amend Requirement #4 to change timeframe to at least 45 days in

advance of OEP. Add mid-year changes to be reported at least 30 days in advance. Add

exceptions for extenuating circumstances.

▪ We understand the concerns about the timeframe and support modifying it. We will monitor this in year 1 to see if timeframe

works well for both insurers and brokers. Added clarification about mid-year changes, assuming Requirement #3 is not finalized.

2021 Plan Certification

Proposed Requirement #4

Page 41: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Proposal Policy Goal(s) Benefits Challenges

Meaningful

Difference

Provide high quality,

affordable,

comprehensive health

coverage to

Commonwealth residents

• Ensure plans provide added

value to the customers of

differentiated features, and

sufficient but not

overwhelming choice

• Can be difficult standard to

quantify

Exchange Authority | 41

▪ Summary of Stakeholder Feedback:

▪ Broad support across consumer groups, brokers, assisters, insurers, providers/health systems.

▪ Support for plenty of choice but understanding that too much choice is overwhelming to customers

▪ Several Insurers sought clarification, including requesting examples of what would pass/fail the reasonable consumer

standard, request that the federal definition and standard be applied for year 1, and recommendation that an easier path

be found for comparing differences in an insurer’s plan networks.

▪ Staff Recommendation: Adopt consideration #1, as written

▪ Staff will provide examples to insurers to provide clarity.

2021 Plan Certification

Proposed Consideration #1

Page 42: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Proposal Policy Goal(s) Benefits Challenges

Avoid Disruption due

to Renewal Plan

Mapping

Seamless autorenewals

for customers into

appropriate comparable

plans

• Ensure customers are

autorenewed into the

most appropriate

comparable plan without

surprises of significant

changes

• Limited time to develop a new plan

mapping standard for 2021 which can be

complex

Exchange Authority | 42

▪ Summary of Stakeholder Feedback:

▪ Broad support across consumer groups, brokers, assisters, providers/health systems, and half of insurers.

▪ Support for trying to most appropriately identify comparable plans from year to year in support of autorenewal, without surprising

customers with significant changes that they might not be aware of until after close of OEP.

▪ 1 Insurer sought clarification on the types of changes that would qualify as “significant disruption”, and recommended that changes

made to plans solely to meeting AV calculator requirements should not be treated as disruptive.

▪ Half of insurers expressed concerns including:

▪ Request to use the FFM standard in 45 CFR 155.335(j) for 2021, and work with stakeholders to develop a PA-specific policy in the

future if appropriate;

▪ Concern that plan mapping should not be part of QHP certification, and suggested that any disruption due to plan mapping should be

handled by notices and customer communications.

▪ Staff Recommendation: Amend to recommend using FFM standard for 2021.

▪ We intend to monitor this issue in 2021 to better understand the extent to which this is an issue impacting Commonwealth

customers, and raise for reconsideration in future years as appropriate.

2021 Plan Certification

Proposed Consideration #2

Page 43: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Proposal Policy Goal(s) Benefits Challenges

Effect on APTC Ensure Pennsylvanians

have continuous access

to high-quality

affordable health plans

• Prevent APTC devaluing

ensures continued

affordability for financial

assistance customers

(88% of marketplace)

• APTC devaluing can occur naturally due

to other factors that we would not want

to stop, including new entrants to the

marketplace, or new products competing

against other insurer products

Exchange Authority | 43

▪ Summary of Stakeholder Feedback:

▪ Stakeholder feedback was mixed. In general, broad group of stakeholders supported the intent of the policy to ensure continued

affordability by avoiding unnecessarily devaluing APTC, however they found the topic complex and challenging.

▪ Half of insurers supported, half said they did not support either because they were concerned it would prohibit competition amongst

other insurers or because there were unsure what actions would be permissible and which would not be under this consideration.

▪ Staff Recommendation: Amend consideration #3 to clarify intent (not to stifle competition), & require

Board approval before taking action based on this consideration

▪ It is very unlikely that this policy lever will ever be pulled as it is only be necessary to protect consumers from pricing strategies

which prioritize market share specifically at the expense of net premium after APTC for all subsidized customers (one known

example in the history of exchanges). APTC value will fluctuate year over year, and in the event it goes down due to price

competition (e.g. new insurer in marketplace, insurers introducing new lower cost products to compete with one another), no action

would be warranted.

▪ Given the potential severity of impact on affordability, we strongly support keeping this consideration available as a tool, but

recommend amending to clarify that this is not intended to stifle competition and to require Board approval to take action based on

this consideration.

2021 Plan Certification

Proposed Consideration #3

Page 44: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

2021 Plan Certification Public Comment and Board Discussion

Exchange Authority | 44

Page 45: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Notice of Benefit and Payment Parameters

45

Page 46: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

▪ What is the NBPP?

▪ Annual federal rule issuing guidance or clarification of previously issued guidance on a variety of ACA programs, including Exchanges.

▪ Draft rule issued 1/31/2020, Public comments due 3/2/2020

▪ Some of the proposed guidance would directly impact the state-based exchange (SBE), or they have requested comment on whether the proposed guidance should be applicable to SBEs

▪ We propose commenting on a few Exchange-specific policies

▪ General comments about need for state flexibility

▪ Special Enrollment Period (SEP) changes

▪ Change to APTC on certain autorenewals

Note: We will not be commenting on parts of the federal rule that are under PID’s purview.

Draft 2021 Notice of Benefit & Payment Parameters (NBPP)

Exchange Authority | 46

Page 47: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

1. State Flexibility

▪ Advocate for state flexibility to implement (or not) any proposed regulatory changes in a

manner consistent with enabling statute and in the best interest of the Commonwealth

and its residents

2. Special Enrollment Periods (SEP)

▪ Support for proposed regulatory changes that increase customer flexibility to use SEPs to

enroll in coverage

▪ Concern regarding changes that would restrict a customer's ability to make an informed

decision about their coverage and when it is effectuated

NBPP

Summary of Comments

Exchange Authority | 47

Page 48: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

3. Proposed elimination of APTC for autorenewals where customer has no cost

premiums

▪ Proposed FFM rule for 2021, requesting comment on whether to require SBEs to implement as well

▪ Renewal Scenario:

▪ Customer is renewed into an auto-renewal policy

▪ Customer’s APTC amount is >= premium

▪ Result to customer is $0 premium for auto-renewal policy

▪ Current Policy:

▪ If no action during OEP, enrolled in auto-renewal policy with full APTC and zero dollar premium.

▪ Proposed Policy:

▪ Customer would be auto-renewed but NO APTC would be applied.

▪ If no action during OEP, customer auto-renewed and responsible for FULL premium.

▪ In order to receive APTC, customer would need to:

▪ Complete a new eligibility application

▪ Make an active plan selection to apply the APTC

Exchange Authority | 48

Draft 2021 NBPP

Summary of Comments

Page 49: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Decision Policy Goal(s) Benefits Challenges

Remove APTC from

Auto-Renewal if Zero

Dollar Premium?

Proposed federal rule,

reduce eligibility errors

& potential government

misspending

• Per rule, protects against

incorrect APTC

expenditures, some of

which cannot be

recovered through

reconciliation process

due to caps

• Scope of the purported issue unclear

• Would create additional barriers to

coverage for customers with greatest

need for assistance

• Change to customer expectations &

understanding of annual renewals

• Technical work to implement

Exchange Authority | 49

NBPP (stakeholder feedback)

▪ Summary of Stakeholder Feedback:

▪ Broad opposition to this policy across all stakeholders (consumer groups, brokers, insurers,

providers/health systems, assisters)

▪ Concern that this would negatively impact the most vulnerable population, create unnecessary

barriers to coverage, and fundamentally change how OEP has worked for the past seven years

leading to customer confusion.

▪ All stakeholders expected this to lead to an increase in uninsured population

▪ Staff Recommendation:

▪ Advocate that this policy adversely impacts vulnerable populations and would increase uninsured

population, and reiterate need for states’ rights to make decisions right for their unique market.

APTC and Auto-Renewals

Page 50: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Review of Proposed Employee Handbook

50

Page 51: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Why create an Employee Handbook?

▪ Human Resource (HR) policies and procedures are necessary to have a successful workplace.

▪ Statutorily, as a state-affiliated agency, we are not directly subjected to the same policies and

procedures as the agencies under the Governor’s jurisdiction.

▪ As a result, the Exchange Authority needs to create its own HR policies and procedures.

What we did

HR, in conjunction with the Office of Chief Counsel, drafted the proposed Employee Handbook.

We remained consistent with the agencies under the Governor’s jurisdiction to the extent possible.

Employee Handbook

Exchange Authority | 51

Page 52: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Special Holidays (Page 9)

▪ Traditionally, a Secretary does not have the ability to call a special holiday, only the Governor (or independent agency head) can.

▪ An example of this was the decision of Governor Wolf to close the agencies under his jurisdiction during the funeral of President Bush.

▪ This policy would give the Executive Director the ability to a) call a special holiday when the Governor does; and 2) create a special holiday for reasons specific to the Exchange Authority, if necessary.

Extraordinary Pay Increases and Bonuses (Page 11)

▪ The ability to issue Extraordinary Pay Increases is consistent with the agencies under the Governor’s Jurisdiction. These are pay increases above what is deemed as the agency-wide cost of living adjustment and are for exceptional service to the Commonwealth.

▪ The ability to issue bonuses is not unheard of in state government, but it is rare. Unlike an Extraordinary Pay Increase – which would change the level of pay an employee receives – this would be a onetime cash payment for quality work performance.

Employee Handbook

Exchange Authority | 52

Page 53: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Recommended Motion: To adopt Version 1.0 of the Exchange Authority’s Employee Handbook,

dated February 19, 2020, as the employee handbook of the Pennsylvania Health Insurance

Exchange Authority.

Employee Handbook

Sections to Note

Exchange Authority | 53

Page 54: Pennsylvania Health Insurance Exchange Authority Board of ... Based Exc… · GC selection set on or before Feb 28 Next phase SDs (Schematic Design) and DDs (Design Development) June

Pennsylvania Health Insurance Exchange Authority

Adjourn

54